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The Department of Health and Human Services (HHS) Office of Inspector General (OIG) recently issued updates to its OIG Active Work Plan (Work Plan) for July 2018.  In 2017, the OIG began releasing its Work Plan projects on an ongoing basis, rather than providing biannual updates.  The monthly updates add new items and remove completed tasks from the Work Plan.  The monthly update schedule ensures that the Work Plan closely aligns with the OIG’s work planning process.  The OIG assesses relative risks in HHS programs and operations to identify those areas most in need of attention.  It considers several factors when creating Work Plan items, including legal mandates, congressional requests, budgetary concerns, potential for positive impact, and others.  In addition to working on projects that often lead to audits, reviews, and reports, the OIG also engages in a number of legal and investigative activities that are separately reported.

The OIG added the following seven items to its Work Plan for July 2018:

  1. ACF Oversight of Guardian Ad Litem Requirements and Reporting
  • States must ensure that every child involved in an abuse or neglect judicial proceeding is appointed a trained guardian ad litem (GAL) as a condition of receiving Child Abuse Prevention and Treatment Act (CAPTA) state grant funding. States self-certify that they have met this requirement through signed assurances to the Administration for Children and Families (ACF).  The Office of Evaluation and Inspections is conducting this review to determine the extent to which ACF oversees states’ compliance with CAPTA’s GAL requirement.  It also seeks to identify challenges that states face which prevent complete and accurate reporting to ACF regarding court representation of child victims.
  1. SAMHSA’s Oversight of Accreditation Bodies for Opioid Treatment Programs
  • Opioid treatment programs (OTPs) provide Medication-Assisted Treatment (MAT) as an integral part of the treatment protocols for opioid use disorder. Previously, SAMHSA issued final regulations, under 42 CFR Part 8, to establish an oversight system for the use of MAT in these circumstances.  These regulations set forth procedures for an entity to become an approved accreditation body that evaluates OTPs and ensures that SAMHSA’s opioid dependency treatment standards are met.  The Office of Audit Services (OAS) aims to determine whether SAMHSA’s oversight of accreditation bodies complied with Federal Government requirements.
  1. Review of Post-Operative Services Provided in the Global Surgery Period
  • The Centers for Medicare & Medicaid Services (CMS) collects data on post-operative services included in global surgeries, as required by section 523 of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). MACRA also requires the OIG to audit and verify a sample of the CMS collected data.  The OAS will determine the number of post-operative services documented in a sample of medical records pertaining to global surgeries.  This number will be compared to the number of post-operative services that physicians reported to CMS.  The OAS will also verify the accuracy of the number of reported post-operative services.  This information will be used to determine whether global surgery fees reflected the actual number of post-operative services that physicians provided to beneficiaries during the global surgery period.
  1. Increased Payments for Transfer Claims with Outliers
  • CMS reduces the Diagnostic Related Group (DRG), Disproportionate Share Hospital (DSH), and Indirect Medical Examination (IME) payments on beneficiary transfer claims, as required by the transfer rule. However, the methodology for calculating cost outlier payments can result in payments being higher than what would have been paid for those claims in a non-transfer context.  The OAS will determine the extent to which additional Medicare outlier payments negate the reduction in DRG, DSH, and IME payments for transfer claims.
  1. HRSA’s Oversight of Funds for Access Increases in Mental Health and Substance Abuse Services
  • The Health Resources and Services Administration (HRSA) administers supplemental funding grants to expand access to mental health and substance abuse services for current Health Center Program grant recipients. These Access Increases in Mental Health and Substance Abuse Services (AIMS) grants are meant to allow for a focus on the treatment, prevention, and awareness of opioid abuse.  The OAS will review the adequacy of HRSA’s internal controls in their process of determining and monitoring AIMS grants and recipients.
  1. Identification of HHS Cybersecurity Vulnerabilities
  • The OAS will perform a series of IT audits at the HHS Office of the Secretary and its Operating Divisions (OPDIVs). This is an effort to identify cybersecurity vulnerabilities and possible compromise of the HHS Office of the Secretary and its OPDIVs’ systems and networks.
  1. Review of Outpatient 3-Dimensional Conformal Radiation Therapy Planning Services
  • Physicians can sculpt radiation beams to the shape of a patient’s tumor using 3-Dimensional Conformal Radiation Therapy (3D-CRT). 3D-CRT is provided in two treatment phases: planning and delivery.  Hospitals use Current Procedural Terminology code 77295 to bill Medicare for developing a 3D-CRT treatment plan.  Through the use of automated prepayment edits, CMS prevents additional payments for separately billed radiation planning services if they are billed on the same date of service as the 3D-CRT treatment plan.  However, for a form of radiation similar to 3D-CRT, Medicare prohibits payments for separately billed radiation planning services when they are billed on a different date of service.  The OAS will determine the potential savings to Medicare if it had implemented the same prohibitions for 3D-CRT planning services.

The OIG Work Plan is available at:

https://oig.hhs.gov/reports-and-publications/workplan/active-item-table.asp.

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